[VoiceOps] T-Mobile SMS Non-Compliance Fines - A Violation of the TCPA / Section 230?

[Peter Beckman]

OK, how have any of you successfully implemented automated tools that
successfully block "Unwanted Content" such as SHAFT and Phishing with very
low false positive rates? And if so, how, or are you using a service, or
are you hoping that your carrier, such as Bandwidth, will protect you
sufficiently?

If it gets past your carrier's filters, and your own automated attempts to
limit the Unwanted Content, and reaches T-Mobile, and someone complains,
are you just planning on paying the fine? Or will you pass it on to your
customer, who might not be who they say they are, and won't pay the fine?

Has anyone on-list had T-Mobile attempt to levy a fine for Messaging
Content against them? If so, how did that go?

Our TOS obviously prohibits such usage, and we put a fair amount of effort
in AUTOMATED monitoring for and shutting down any violations as proactively
as we can, being a small business without tons of technical resources to
pass every SMS and Full Conversation through ChatGPT to get its opinion if
the content seems like a Social Engineering attempt.

And sure, in hindsight anyone looking at a conversation after the fact can
see a pattern that might be phishing.

How is **EVERY CARRIER** small and large supposed to implement this without
incurring thousands of dollars in costs to do so?

And yes, you can say "Just don't send to T-Mobile then" but we all know
that blocking an entire US Wireless Carrier is not a saleable service to
customers.

Beckman



On Wed, 20 Dec 2023, Calvin E. via VoiceOps wrote:

> What legal grey area? Every carrier I've worked with monitors the content
> of MMS and SMS and will block outgoing messages, per CTIA guidelines.
> Carriers are already expected to block SHAFT content and other
> misuse/abuse, and some will even return specific errors when this happens.
> It's unfortunate that the FCC is allowing T-Mobile to surcharge every part
> of the messaging lifecycle, e.g. I learned recently that T-Mobile
> surcharges carriers on both directions of traffic, unlike others who only
> surcharge to send messages to them.
>
> For those not familiar with the CTIA Messaging Principles & Best Practices:
> https://www.ctia.org/the-wireless-industry/industry-commitments/messaging-interoperability-sms-mms
>
> Current version:
> https://api.ctia.org/wp-content/uploads/2023/05/230523-CTIA-Messaging-Principles-and-Best-Practices-FINAL.pdf
>
> The CTIA Messaging Security Best Practices also touch on content, blocking,
> and sharing content when necessary:
> https://www.ctia.org/the-wireless-industry/industry-commitments/messaging-security-best-practices
>
> Current version:
> https://api.ctia.org/wp-content/uploads/2022/06/Messaging-Security-Best-Practices-June-2022.pdf
>
> Take a look at
> https://support.bandwidth.com/hc/en-us/articles/360000111087-SMPP-SMS-Delivery-Receipts-and-Error-Codes
>
> 470
> spam-detected
> This message has been filtered and blocked by Bandwidth for spam. Messages
> can be blocked for a variety of reasons, including but not limited to
> volumetric filtering, content blocking, SHAFT violation, etc.
>
> 481
> rejected-from-number-in-blacklist
> The From number has been flagged by Bandwidth as prohibited from sending
> messages. Numbers can be added to a blacklist when they are associated with
> messages that repeatedly violate spam policies, fraud policies, or
> messaging AUP.
>
> 770
> destination-spam-det
> The Carrier is reporting this message as blocked for SPAM. Some examples of
> common spam blocks: unwanted content, SHAFT violations (including specific
> keywords), or originating address has been flagged for repeated spam
> content.
>
>
> On Wed, Dec 20, 2023 at 10:41 AM Jay Hennigan via VoiceOps <
> voiceops at voiceops.org> wrote:
>
>> On 12/20/23 10:24, Peter Beckman via VoiceOps wrote:
>>> I received this information from Bandwidth 2 days ago:
>>>
>>>
>> https://support.bandwidth.com/hc/en-us/articles/19939626519575-New-non-compliance-fees-on-January-1
>>>
>>> T-Mobile is stating that starting January 1, 2024, they will be fining
>>> carriers for every SMS that violates these three tiers of unwanted
>>> messaging:
>>
>> [snip]
>>
>> This sounds kind of like Mr. T deciding to fine T-Mobile $10,000 a day
>> for having a name that starts with "T". How would he collect, or would
>> he just pity the fools that came up with the idea?
>>
>> --
>> Jay Hennigan - jay at west.net
>> Network Engineering - CCIE #7880
>> 503 897-8550 - WB6RDV
>>
>> _______________________________________________
>> VoiceOps mailing list
>> VoiceOps at voiceops.org
>> https://puck.nether.net/mailman/listinfo/voiceops
>>
>

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Peter Beckman                                                  Internet Guy
beckman at angryox.com                                https://www.angryox.com/
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